Transformations to Discourse and Legal Provisions Concerning “International Marriage”. Understanding Theories on Race and Racialization in Modern Japan

(Graduate School of Intercultural Studies - Kobe University)

Discourse on racism was imported to modern Japan as a body of academic thought. There is a semantic gap between “race” (in English) and jinshu (its Japanese equivalent), and the history of the concept’s evolution also differs. Given this, what objects of study shed light on continuities and changes in “racialization” in Japan? Recent debate has focused on the history of discourse on “konketsuji” (mixed-blood children). The modern nation state presumes the homogeneity of a nation’s language, race, ethnicity, and culture. The fact that such a presumption is a fiction simultaneously aroused a desire for “purity”, while triggering excessive discourse on “konketsu” (mixed-blood) and on “konketsuji” (mixed-blood children) who disrupt this “purity”. Research has focused on the period when questions were raised over the introduction of the concept, on the period of colonial expansion when debate developed based on eugenic perspectives, and on the period of post-war Allied occupation when cultural representations were problematized. Hence a particular characteristic of Japanese discourse on racial mixing is that its role in creating the category of “the Japanese” was played out under the alternating conditions of colonizer and colonized (Oguma Eiji). A further specificity is that Japan is placed in a “doubly twisted hierarchical relation” between “the West” and “Asia” (Iwabuchi Koichi).

In this paper, I discuss historical periods of discourse on “mixed-blood” via the issue of “kokusai kekkon” (international marriage). I do so because I want to consider “racialization” by viewing the concept of race in terms of slippages in discourse. At the same time, movement and contact between people preceded the creation of modern state institutions and “naming”. The issue of international marriage thus enables us to examine the contexts in which racialist discourse is used.

1) Policies for dealing with international marriage were quickly put into effect when Japan opened up the country. They included the issue of the transfer of individuals’ ie (household/status) (Okuchi Yujiro, Morita Tomoko). It was possible for a Japanese woman who married a European or American man to belong to the household/status of her husband, and for a European or American man who married a Japanese woman to belong to her household by becoming an adopted son. This was set out in an early Meiji law (“Article on the Marriage of Japanese and Foreign Nationals” 1873). This is law, which preceded the Nationality Act (1899), provided for such changes in nationality, causing some countries, especially the UK, to protest (Kamoto Itsuko).

In her most recent research, Kamoto argues that the idea of this 1873 Act stemmed from the Napoleonic Code of the 1800s, which introduced the principle of patrilineality and of a married couple having the same nationality1. Kamoto examines cases of intermarriage from the 1870s to 1880s, mainly with people of European and American origin (mainly through the records of international marriage kept by the Ministry of Foreign Affairs and the Home Ministry). From these cases, she finds that the Japanese government built up knowledge of the standards of civilized countries, and came to appreciate the need for a Nationality Law determining the country to which a person belonged, instead of transferring a person from one household status to another. Kamoto defines the institution that understood international marriage in terms of a person’s affiliation to household status as the “principle of social status (bungen shugi)”, and argues that it was an intermediary stage in the evolution of the legal system.

Nihon jinshu kairyo ron (1884), Yoshio Takahashi

Yoshio Takahashi’s Theory of Japanese Breed Improvement (1884) introduced the concept of mixed race.

Given this historical context, it should be clear why the Enlightenment thinkers of the Meiji period insisted on the introduction of monogamy, while also being highly critical of the system of adoption. This was because those who had studied international law at the time and were responsible for “civilizing” Japan were very much aware of the fact that international marriages involved problems of jus sanguinis. Based on a study of modern dictionaries, Okamura Hyoue has examined the process by which vocabulary relating to the concept of mixed-blood was taken up and transformed in the Meiji period. He points out that eugenic perspectives and vocabulary in Takahashi Yoshio’s Theories on Improving the Japanese Race (Nihon jinshu kairyo ron, 1884), where the idea of mixed-blood is said to have first appeared, were used in the context of discussing “zatsukon no koto” (issues on inter-racial or inter-ethnic marriage). Moreover, international marriage brings to the fore the significance of the gender division bound up with racialist discourse. The modern nation state classifies people according to gender and is founded on compulsory heterosexuality based on the principle of the modern family with a male head of household.

Enlightenment thinkers of the early Meiji period expanded on debates which were then taken up by Takahashi as the basis of his theories on racial improvement. The journal Meiroku zasshi, for example, contained many debates on how marriage related to patrilineal jus sanguinis. Mori Arinori expounded the modern family norm of inheritance by children of the patriline, reimporting the principle of jus sanguinis with the customs of the European upper classes firmly in mind. He advocated monogamy, and strongly criticized the custom of Child adoption or yoshi engumi that allowed inheritance by those not born to the husband-and-wife couple. He pointed out the reason for abolishing the custom of adoption was that it went against the European way of upholding true pedigree, in addition to being a corrupt practice placing importance on the “woman’s blood line”. Fukuzawa Yukichi also criticized adoption in similar terms. The theories of Takahashi, who was Fukuzawa’s student, led to Kato Hiroyuki’s critique of the same period, who took the example of the Russian Emperor’s marriage as an argument for patrilineal jus sanguinis. The discourse on jus sanguinis as a new order to replace status was promoted by intellectual giants of the early Meiji period as a social model common to modern Europe and America. The discourse was developed in discussions on the norms of the modern family based on patrilineality, and included racialist terminology. It became a technique of governance for creating a civilized “nation”, as well as a concept that could be manipulated.

Binzo Kumano (1890)

A commentary on the Meiji Civil Code, edited by Binzo Kumano (1890), in which the concept of “lineage principle” is introduced.

2) From Kamoto’s research, we can clearly understand the following. The “principle of social status” was taken up in response to the mixing of different groups. This principle historically preceded the Nationality Law (1898) is the principle which is based on the nineteenth-century principle of the husband and wife having the same nationality. Here we may note the origin of the Japanese nationality system in which the family register and nationality are intricately linked. Legitimate marriage in nineteenth-century Japan was monogamous legal marriage, which was thought to be the standard in “civilized countries”. Marriage systems in the colonies became a significant issue of debate from the point of view of legal marriage as the “civilized” norm.

In Japanese colonies from the nineteenth to twentieth centuries, the colonized became imperial subjects. Marriages between Japanese and Koreans were called naisen kekkon and those between Japanese and Taiwanese naitai kyokon. There is much interest in and research on the former as it was part of the ideology of the assimilation policy. But, if the discourse of racism emphasized differences between groups of people, any racist elements in discourse on marriage between the Japanese and the colonized Taiwanese and Koreans were in fact unclear, with cultural similarities being emphasized. However, it took a long while for legal marriages in the colonies to be institutionalized: it was not until 1921 that the Cabinet granted legal recognition to an adjective law on how marriage in Korea between Japanese and Koreans was recorded in the family register, and later still, in 1933, for marriage between Japanese and Taiwanese in Taiwan.

Colonizers’ discourse and laws on intermarriage between colonizers and colonized are important. Subjects of the Japanese Empire were classified into Japanese, Korean, and “Han Chinese” (Taiwanese), according to the locations of the family registers and accounting books in which they were registered. The important point about the marriage system was that although the Japanese Empire’s colonial policy was based on the principle of assimilation, the laws and regulations regarding family registers applicable in Japan were different to those in the colonies. In the case of Taiwan, family registers were only introduced at a late stage, and the principle of the modern legal marriage was not extended, for there were no legal provisions applying the Japanese system of legal marriage to inhabitants of the colonies. As regards implementation of the law, Japan neither prohibited marriages between Japanese and Koreans and Taiwanese in the early colonial period, nor provided any incentives. Intermarriage was not controlled.

However, since Japanese colonial rule in the nineteenth century followed the lines of a “civilizing mission” of universal modernization, it was easy for the white man’s discourse on racist policies to slip into no control and laissez faire. In the early period of rule over Taiwan, the Taiwanese aborigines were represented as savage races2. In the case of Taiwan, the assimilation ideology, implemented through marriage and assimilation, was based on excluding Taiwanese aborigines. A famous Japanese lawyer of the Meiji Period, Hozumi Nobushige, presented a critique in an essay written in the 1930s, “Marriage between Japanese and Taiwanese (Naitai kyokon)”. He pointed out that Taiwanese and Koreans could marry the Japanese when they were “foreigners”. However, paradoxically, they could not be legally married to the Japanese when they all became “Japanese” because each came from different jurisdictions. Common Law provisions (kyotsu ho, 1921) introduced to remove differences in jurisdiction also had many problems. Legal marriage required family registers, and it only became possible in Taiwan after the establishment of the Taiwanese Family Registration Order (Taiwan koseki rei). As Hozumi pointed out, intermarriage in Korea and Taiwan meant that “when a Japanese woman marries a Korean man and is registered in a Korean family register, she will no longer be registered in a Japanese family register”. At the same time, Hozumi assumed that “marriage between Japanese and Taiwanese” meant marriage with persons of the Han race. During the period of Common Law, the aborigines were divided into two categories, the “assimilated (jukuban)” and the “unassimilated (seiban)”, according to their degree of assimilation in Han culture. Marriage between Japanese policemen and headmen’s daughters was part of a policy to bring about harmony between the ruler and the ruled (waban konin).


What about the much-researched cases of marriage between Japanese and Koreans? Previous research has focused on how marriages between Japanese and Koreans were viewed as a sensitive issue in colonial society. This was because the expectation embedded in discourse of assimilation was that intermarriage would promote the Japanization of Koreans. Recent research by Lee Jeong-Seon suggests that in the early years of the annexation of Korea at the beginning of the twentieth century, policy towards intermarriage was laissez faire, but the slogan “marriage between Japanese and Koreans” arose with the development of assimilation policies3. However, in Korea, “Common Law” provisions together with the Korean Family Registration Order (1922) meant that there were no limits placed on the location of marriage or on the combination of sexes. Both adoption and husbands marrying into their wives’ families (groom-taking, muko-iri) were legally possible. Marriage between Japanese and Koreans led to the husband and wife becoming Koreans, and the family register and household they belonged to prior to marriage were changed. Here too, adoption (yoshi engumi) and marriage meant expulsion (joseiki) from the original family register.

"Enfants de sang mêlé" | "Mix race children on Nanyou", 1939

“Mix race children on Nanyou”, Keio University, Tamezo Eguchi, 1939.

The table shows Lee’s classification of the “legal status of children of Japanese-Korean intermarriage”. Lee suggests that freedom of marriage under the system of legal marriage was promoted by the policy of “harmony between Japan and Korea (naisen yuwa)” of the Governor-General of Korea in the 1920s. At the same time, however, a new sense of crisis emerged over boundaries, as feelings of aversion among Korean society led to ideologies of “blood”, such as “purity (junketsu) of the Korean race” and “pureness (junketsu)”; the Japanese too became cautious about becoming Koreanized. Lee says that such caution reached a peak in the 1940s during World War II. The table below sets out the nationality attributed to “mixed-blood children”.

  legal marriage extra-marital relation
  marriage nyufu1 / muko yoshi2 shoshi3 shiseiji4
Korean man - Japanese woman Korean Japanese Korean Japanese
Japanese man - Korean woman Japanese Korean Japanese Korean

*nyufu : husband marrying into wife’s family

**muko yoshi : groom adoption

***shoshi : illegitimate child recognized by the father

****shiseiji : illegitimate child unrecognized by the father

3) The state of all-out war also shook old boundaries, requiring a new logic of inclusion and exclusion. Unlike in the nineteenth and early twentieth centuries, eugenics-based military discourse during the Asia-Pacific War was closely linked to racism fraught with an ideology of “blood”. During the Sino-Japanese War in 1939, the media began a negative campaign against “mixed-blood”. A newspaper article titled “Problems that occur due to expansion in the [Chinese] continent” asked “What would be the results of marriage with different races and mixed-blood children?” (24 April, Yomiuri Shinbun).

Assimilationist discourse was criticized in 1940, just before the Asia-Pacific War, with the same newspaper asking: “Marriage within the Co-prosperity Sphere: What would be the eugenic consequences?”; its answer – “Cannot predict a good result” – led it suggest: “Get rid of the idea that international marriages will lead immediately to amity” (8 October, Yomiuri Shinbun). An official document (July 18, 1942) of the Japan army occupying the Philippines after war broke out discussed the treatment of “mixed-blood children” in military concentration camps. If the father was an enemy national, the “mixed-blood” child would be treated as an enemy national. The “nationality principle” in this case was based on patrilineal nationality. “Mixed-blood women” married to non-enemy nationals, children with Filipino mothers, who could be proven “harmless” by their Filipino relatives, and those with dual nationality were considered harmless.

Manchukuo (1942)

A text for female settlers (1942) edited by the Ministry of Manchukuo insists that ethnic purity must be maintained.

In contrast, Japanese eugenic racialist discourse about Korea was hardly effective as a logic of exclusion4. Here we may refer to recently cultural studies about Korea that are deeply connected with racialist discourses. Kamoto criticizes historical studies - this mean “studies looking at the history of Korea” – that include modernist terminology, pointing out, “Are these studies not applying white men’s racist policies as Tokugawa policies?” In this regard, we need to consider the fact that research conducted in the 1930s and 1940s about Southeast Asia introduced European and American research on “mixed marriages (zakkon)”.

We also need to reconsider the fact that knowledge about harmonious inter-racial marriage in Southeast Asia, such as research on mixed-blood children in the sixteenth century before the closing of the country, was classified as research on “Japanese history” up until World War II. However, since Japan started a war with Southeast Asia in World War II, as was the case in the Philippines occupied by the Japanese military, discourse on international marriages addressed issues about which country a child should fight for as a soldier in a war between his father’s and his mother’s country. The principle of the husband and wife having the same nationality thus needed to be replaced by that of each having independent nationalities.

How does the modern state define the meaning of the relationship between men and women and place it in the network of institutions? What is the place of racialist discourse in this process? Many questions and debates during the expansion and contraction of Japan’s empire in nineteenth and twentieth century still await exploration.

Unfold notes and references
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Kamoto, Itsuko, “Dealing with Children of Mixed Heritage: From Tokugawa to Meiji” (in Japanese), Rekishi Hyoron [Historical Journal], vol. 815, March 2018. Kamoto’s article is part of a special edition of Rekishi Hyoron titled “History of Mixed-blood Children between Japanese and ‘Outsiders’”. The editor, Takemoto Nina, uses Takezawa Yasuko’s five structural factors of racial mixing in Japanese society as a starting point of her discussion.

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Chia Chi Huang classifies marriage between Japanese and Taiwanese into four stages: 1) The early colonial period through to the early twentieth century as a stage when there were no specific plans (1896-1906). 2) A period up to the “Law accommodating marriage between Japanese and Taiwanese (naitai kyokon bengiho)” in 1920 as a stage when mixed marriages were promoted (1906-1920). 3) A period up to the 1933 “Law on marriage of Japanese and Taiwanese (naitai kyokon ho)” as a pre-legal stage (1920-1933). 4) A period after 1933 as a stage of legal marriage (1933-1945). See, Chia Chi Huang, “Structure and development of ‘naitai kyokon’ in the period of Japanese rule” (in Japanese), Hikaku kazokushi kenkyu [Journal of Comparative Family History] vol. 27, 2012.

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See Jeong-Seon Lee, “Children of ‘Japanese-Korean Intermarriage’ under the Colonial Rule” (in Japanese), Rekishi Hyoron [Historical Journal], vol. 815, March 2018.

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Lee focuses on the fact that imperial Japan’s population policy during World War II included eugenic ideas about mixed-blood. The Japan Society for the Promotion of Science set up the “11th Special Committee on Ethnological Research on Issues of Inter-ethnic Contact and Mixed-blood” (1939), and published a report, “Photographs of facial measurements of families of Japanese-Korean Intermarriage”. On the basis of these examples, Lee points out the limitations of problematizing issues from racialist perspectives.